Submission to the Justice Select Committee’s inquiry into women in prison from Her Majesty’s Chief Inspector of Prison

1. We welcome the opportunity to submit a response to the Justice Select Committee’s inquiry into women in prison.
2. Her Majesty’s Inspectorate of Prisons (HMI Prisons) is an independent inspectorate whose duties are primarily set out in section 5A of the Prison Act 1952 and include reporting on the conditions for and treatment of women in prisons and young offender institutions (YOIs) in England. HMI Prisons also inspects outcomes for girls in secure training centres (STCs) together with Ofsted and the Care Quality Commission.
3. HMI Prisons inspects all women’s prisons in England against our Expectations: Criteria for assessing the treatment of and conditions for women in prison, the second version of which was published in April 2021.¹ The updated Expectations emphasise the role of healthy relationships in underpinning women’s safety and the importance of women maintaining relationships with children and families; and recognise the impact that trauma can have on the lives of women in prison. These Expectations were developed through extensive consultation, including focus groups with women in custody, and are underpinned by human rights standards.
4. Our below response sets out our findings from women’s prisons regarding trauma-informed approaches; self-harm; relationships with children and families; and rehabilitation and release planning. Our findings are from:
   • six full inspection reports published between 2019-20 and 2020-21;
   • short scrutiny visits and scrutiny visits which were conducted in response to the COVID-19 pandemic using an adapted inspection methodology;² and
   • our thematic review, What happens to prisoners in a pandemic?, which explored prisoner’s experiences of the restrictions which were introduced during the pandemic.
5. Our response also sets out our findings from recent inspection reports of STCs and our annual Children in Custody surveys in relation to outcomes for girls. These findings are from the period before the pandemic, except where stated otherwise. We hope that our response will assist the Justice Select Committee in its inquiry into women in prison.

6. Inspectors have found that more work needs to be done across women’s prisons to embed a trauma-informed approach. The number of staff who had been trained to consider the trauma women may have experienced varied – for example, only 37% of staff at HMP & YOI Foston Hall had been trained at the time of our full inspection, whereas more than 90% of staff were trained at HMP & YOI New Hall and HMP & YOI Askham Grange. Inspectors also found that the application of trauma-informed principles varied amongst trained staff. At Foston Hall, inspectors found that some staff had not adopted a trauma-informed approach or practice, which meant the management of some women in crisis was not always in line with their trauma-based care plan. However, staff we spoke to at HMP/YOI Drake Hall and HMP & YOI Bronzefield understood how trauma affected the behaviour, well-being and offending of women in their care and at New Hall, a prison-wide, trauma-informed model of care was in the early stages of implementation.
7. Identification of women who have experienced trauma needed to be more sophisticated at some prisons. Peer workers who were trained in trauma identified women’s needs on arrival at two inspected prisons, which was a useful addition. At some prisons, there was a good range of support available (which included therapy and counselling) for women who had previously experienced trauma. Peer-led support for women who had previously experienced trauma was also available at half of the prisons we inspected. During our scrutiny visit of Peterborough, inspectors found that a dedicated team of prison staff and trauma champions had continued to provide face-to-face support for women throughout the pandemic.
8. The conditions in some women’s prisons that received full inspections were not always conducive to trauma informed principles. Living conditions varied across and within individual establishments and inspectors found poor or cramped conditions in cells and on living units. Some prisons had insufficient privacy screening for showers and toilets in shared cells, and some units were bare, dark and unappealing. Although most prisons had well maintained outside areas, women’s access to these was insufficient at a few prisons. In addition, few prisons had insufficient space for support work to take place – for example, the lack of confidential therapeutic space at Drake Hall hindered the delivery of group therapies for women.

9. We expect there to be an effective self-harm reduction and suicide prevention strategy which is underpinned by regular analysis of incidents, and a robust action plan which relates to the whole prison. Only two prisons inspected had a detailed strategy to reduce the levels of self-harm, but neither strategy was informed by data analysis. At New Hall, self-harm data were analysed for trends, but there was no specific strategy or action plan for reducing self-harm.
10. In almost all prisons inspected, levels of self-harm were often attributed to a small number of women with high levels of need. For example, at Foston Hall, 900 self-harm incidents had taken place in the six months prior to the full inspection and six prisoners accounted for over half (52%) of these incidents.
11. The quality of care and support for women at risk of self-harm was generally good but there were some gaps. Peer workers were used effectively to offer emotional support to women at
    most prisons. Women at risk of self-harm who were being managed through the assessment, care in custody and teamwork (ACCT) process felt well supported at all inspected prisons. However, the quality of recording in ACCT case management documents was only good at half of
    the prisons inspected and needed improvement.
12. Staff-prisoner relationships were mostly positive, but staff support for women at risk of self-harm was insufficient at some establishments. At half of the prisons that received full inspections, we found that staff were knowledgeable about the women in their care, their needs and their self-harm triggers. We saw most staff respond appropriately to those in crisis. However, staff at Foston Hall did not proactively support women and only reacted to incidents of self-harm, rather
    than working to prevent any triggers. We only found effective personal officer schemes at two inspected prisons. Although all women at Drake Hall reported having a personal officer in our survey, too many women said they had not spoken to their personal officer since arriving and less than half (49%) said they found them helpful.
13. During the pandemic, the level of self-harm for women in prison remained high throughout with some peaks. In our thematic review, inspectors found that long periods of isolation had led to women using unhealthy coping strategies more often (such as cutting). At the beginning of the pandemic, inspectors found that additional well-being checks had been introduced at all women’s prisons that received a short scrutiny visit. However, we were concerned that women
    with high levels of need were still struggling to cope, as interventions they had received before the pandemic (such as specialist mental health support) had been curtailed. The lack of opportunity for meaningful engagement with peers and staff had also deepened some women’s distress. During our scrutiny visits, too few women who spoke to inspectors and had been supported through the ACCT process felt cared for by staff. Similarly to before the pandemic, the ACCT documentation we reviewed during our scrutiny visits was sometimes weak and did not provide a clear record of ongoing support.

14. We expect prisons to have a comprehensive strategy and action plan that promotes women’s relationships with their children and families, which is underpinned by a needs analysis and regularly reviewed.³ While there was positive support for women to maintain their family relationships at all six prisons inspected, less than half had a comprehensive and needs based strategy in place.
15. Inspectors found that effective family support workers were in place at all six prisons, who offered guidance to women, arranged visits and had good relationships with community-based agencies. At many prisons, specialist support was available, such as parenting and relationship courses or counselling for women who had been separated from their children. ‘Storybook Mums’ (where women record a story that their children can listen to) was reported to be running
    at half of the prisons inspected.
16. Most visitors’ spaces were suitable for children and had play areas. Some prisons held regular family days or all-day visits with support workers who helped women and their children play together. Most prisons had designated and private spaces where mothers could spend time with their children and families. For example, children of women prisoners at Drake Hall and Askham Grange were able to visit overnight.
17. Women’s contact with their families was negatively impacted during the pandemic. The suspension of social visits meant that many women had not seen their children for months. Women interviewed for our thematic review said that not being able to see their children left them feeling lonely, frustrated and anxious. Even when social visits recommenced, the restrictions in place meant uptake was low. For example, at Peterborough, inspectors found the limits on the number of children who could attend, the ban on physical contact and the reduced time slots had dissuaded women from booking visits due to the emotional distress it caused them and their children.
18. The introduction of video calling to help women keep in touch with their families during the pandemic was positive. However, implementation had been slow and initial uptake was low due
    to some ongoing technical problems. Other communications channels, such as the ‘Email a Prisoner’ scheme continued, and staff gave women additional phone credit, which helped them
    to maintain relationships.
19. Access to family support workers during the pandemic varied. Inspectors found face-to-face family support staff remained on site at Bronzefield and Peterborough, however, others withdrew at the beginning of the pandemic and were only providing limited, remote services. Inspectors have found that full services have been slow to return to women’s prisons – for
    example, the family engagement worker at HMP/YOI East Sutton Park was still not based on site full-time at the time of our scrutiny visit in April 2021, approximately a year after the nationwide restrictions were first introduced.

20. Resettlement work for women being released was mostly good before the pandemic. The use of release on temporary license (ROTL) varied too much at the closed prisons inspected and was not used often enough to support resettlement. At the beginning of the pandemic, almost all ROTL opportunities for employment and family visits had been suspended, which women found frustrating.
21. There were significant gaps in the availability of suitable and sustainable accommodation for women on release and too many were released homeless or to very short-term accommodation. None of the prisons inspected accurately measured the suitability or sustainability of the accommodation into which women were released. During the pandemic, many women continued to be released without accommodation. At the time of our short scrutiny visits, 40% of
    women released from Bronzefield and Eastwood Park and 20% of those released from Foston Hall had no accommodation on the day of their release.
22. Since the beginning of the pandemic, resettlement staff had mostly withdrawn from prisons and were only providing remote services. The lack of face-to-face discussions regarding women’s resettlement needs often undermined effective release planning. Many women found the lack of face-to-face contact frustrating – only 33% of women surveyed at Eastwood Park and 38% of women surveyed at Peterborough during our scrutiny visits reported that someone was helping
    them to prepare for their release.
23. Before the pandemic, the availability of offending behaviour interventions varied, and some prisons lacked a needs analysis to inform them of the provision needed. Accredited offending
    behaviour programmes had been suspended at the start of the pandemic and women reported frustration that their progress had stalled. Where programmes had resumed, staff had adapted them for smaller groups and access was prioritised based on women’s needs. However, these restrictions meant that far fewer women had the opportunity to participate.

24. Inspectors found that more strategic work is needed to identify and address the needs of girls at STCs and young women in adult prisons. There were limited consultation opportunities for girls to present their needs. For example, at Rainsbrook, a girls’ well-being group had been postponed due to staffing issues and prior to the closure of Medway STC, no girls were involved in a youth council. At half of the adult prisons inspected, some forums and focus groups for younger women were being conducted.
25. Girls in STCs have not always received an equitable level of support and provision as boys. At Rainsbrook STC, inspectors found that whilst boys were placed in a specialist induction unit with targeted support on arrival, there is no equivalent induction for girls. In our annual children’s survey in 2018-19, only 39% of girls held in STCs reported that they had been told everything they needed to know about the establishment within their first few days (compared to 76% of boys). Similarly, boys who demonstrated positive behaviour at Rainsbrook could progress to an enhanced unit, whereas there was no equivalent unit for girls. During the pandemic, inspectors
    found that the lack of separate provision for girls at Rainsbrook meant that girls were subject to more restrictive isolation arrangements than boys, as they had to self-isolate in their residential unit. In December 2020, inspectors found a girl who was confined to her bedroom for almost 23.5 hours each day for six days, as she was placed on a residential unit with others who were no longer isolating.
26. During our full inspection of Rainsbrook in February 2020, we found that despite the increased hours that children could spend in enrichment activities, girls’ participation had not increased, and no analysis had been done to understand why. Most adult prisons had some provision for younger women, such as gym sessions and a weekly group, and staff at Bronzefield were developing an achievement award for young women.
27. Inspectors have found evidence that force is used is proportionately against girls in STCs and young women in some adult prisons. For example, at Medway STC, inspectors found that girls accounted for 100% of Minimising and Managing Physical Restraint (MMPR) incidents in November 2019, despite only representing approximately 16% of the population at that time. More recently, in the adult estate, a disproportionate number of incidents at Peterborough involved young women and inspectors had concerns about the use of force and segregation of young women at Eastwood Park.

28. Overall, outcomes for women before the pandemic were mostly good, although improvements were needed in some key areas, such as reducing self-harm. The pandemic has negatively impacted on women’s mental health, family contact and resettlement, which needs to be mitigated. Gaps in the provision for women include:
    • Most women’s prisons need to implement comprehensive, whole-prison strategies and action plans to reduce self-harm and suicide and promote women’s relationships with their children and families;
    • Staff who have received trauma-informed training should be supported to adopt a trauma-informed approach in how they work with women;
    • All women should have a dedicated member of staff who knows them and supports their personal well-being;
    • Women’s resettlement and rehabilitation could be improved by greater access to ROTL and tailored offender behaviour programmes that meet their needs; and
    • Women should be helped to maintain or find accommodation and have somewhere suitable and sustainable to live.
29. Inspectors have found that girls in custody do not receive an equitable level of support.

I hope that you find this information useful and should you require anything further, please do not hesitate to contact me.

Charlie Taylor
Chief Inspector of Prisons
June 2021